Storage Tank Rule - five year milestone - defects to be cited
The five-year anniversary of Regulation 11, Section 11.28, better known as the Storage Tank Rule, is coming in April 2021. Why does that matter? There are two important things to remember about this milestone: 
- First, comprehensive inspections of all finished water storage tanks must be completed, as required by 11.28(2)(a)(iii)(B).
- Second, after five years of periodic inspections by suppliers, the department will begin citing any sanitary defects observed during sanitary surveys as violations of the storage tank rule.
Increase public health protection
The Storage Tank Rule was designed to increase public health protection by having suppliers routinely inspect finished water storage tanks so that sanitary defects would be rapidly identified and corrected. This goal is achieved through three key activities:
- Quarterly periodic inspections of all unpressurized tanks downstream of the entry point, unless an alternative plan is approved
- Comprehensive tank inspections conducted at least once every five years.
- Fix any problems detected during these inspections
Our sanitary surveys over the last three years show that the second most common finding is a sanitary defect at a finished water storage tank - accounting for 12% of all sanitary survey findings during this period. Often these are problems that should have been identified during a periodic inspection and corrected quickly: cracked, missing, or incomplete hatch gaskets; holes or breaches in the tank that are easily identified by rust accumulation; and tank overflows without proper protection.
Identify and Repair
The goal of the Storage Tank Rule is to quickly identify and repair such sanitary defects after periodic inspections. Relying instead on the three- or five-year sanitary survey to identify them does not adequately protect public health. After Oct. 1, 2021, the department will cite sanitary defects identified at finished water storage tanks during sanitary surveys as violations of section 11.28(4)(b)(iv) of Storage Tank Rule. This violation of Regulation 11 is a treatment technique violation and will require distribution of Tier 2 public notice within 30 days.
What can suppliers do to prepare in the meantime?
Start with the guidance and forms on the department’s storage tank rule webpage. Read the guidance and familiarize yourself with the forms. These resources describe what the department is looking for regarding sanitary defects and tank inspections.
During your sanitary survey, discuss the results of earlier periodic inspections with your inspector and describe how you addressed any sanitary defects. Inspectors are more than willing to help suppliers implement their storage tank inspection plans and processes to ensure that sanitary defects are quickly addressed. The department and the supplier share the same goal – Always Safe Drinking Water.
➽ Greg Naugle, former field services manager
